Memorandum by United Biscuits (UK) Limited
international food business operating in 21 countries.
It has leading market positions in the UK, Continental Europe
and is building its presence in Asia. It has 46 manufacturing
sites world-wide and its products are available in over 90 countries.
Over 20,000 are employed worldwide of which 16,000 are based in
Today United Biscuits comprises two main operating
divisions: McVitie's Group, the third largest biscuit company
in the world and UK Foods Group which together manufacture, market
and distribute a wide range of food products.
Brands include household names in all product
categories. Some famous brands include McVite's Digestive, Penguin,
and Go Ahead! products, KP Nuts, Hula Hoops and Phileas Fogg snacks.
Frozen and Chilled products include Linda McCartney meat-free
products, Young's seafood, Ross Chip Shop range and San Marco
pizzas. International brands include BN, Verkade, Fazer, and Gyori.
2. UB recognises that genetic modification in
agriculture could bring many benefits. These are widely acknowledged
and include the following: plants with increased pest and disease
resistance; reduction in the use of herbicides and pesticides;
energy savings in farming; less soil erosion; crops with altered
environmental tolerance; and food ingredients modified to improve
3. UB is committed to providing its consumers
with products of consistent good quality and value which will
appeal to consumers. Furthermore, product safety is an absolute
priority. We will therefore use genetically modified ingredients,
provided we are confident that they are approved safe and deliver
benefit for society. We support the appropriate regulation of
genetic modification in agriculture as essential to assure product
safety and welcome the opportunity to express our views to the
Select Committee on this subject.
4. UB recognises that the proper regulation
of genetic modification will play a critical part in addressing
consumer concerns, through effective and scientifically based
risk procedures. However, we stress that proper regulation alone
cannot guarantee consumer acceptance of the new technology. That
can onlyand mustbe achieved through a broader programme
of education and information in which government, consumers and
all parts of the food chain participate.
5. The control of research is well regulated
in the UK; no significant safety issues have arisen in over 20
years of research and development. In fact the success of the
UK system has led to it being used as a template by many other
6. We are aware that many scientists feel that
the "Contained Use" regulations are unnecessarily restrictive
given the exemplary safety record that exists.
7. Another criticism is that the procedures
underpinning the regulations are focused on micro-organisms and
are thus inappropriate to the wider applications of genetic modification.
This point was made in the 1993 Select Committee on Science and
Technology Report on the Regulation of the UK Biotechnology industry
and Global Competitiveness.
8. We therefore support initiatives to revise
the regulations to adopt a risk-based approach. However, in the
current political climate any such changes would need to be presented
very carefully to the public; failure to do so is likely to lead
to further consumer backlash against the technology.
Release into the environment
9. UB recognises that the system of controls
in place is very well established and that the work of the Advisory
Committee on Releases into the Environment (ACRE) is highly respected.
10. The European Directive however has led to
a number of problems. It has not been implemented consistently
throughout the Member States and in practice procedural delays
in getting approvals mean that researchers in Europe are at a
significant competitive disadvantage compared with those in the
11. We support initiatives to simplify the EU
system. All procedures implementing the regulations should be
transparent and timely. We also support the important role that
consumer representatives can play in the decision making process;
the EU system should mirror the UK system in this regard.
12. We do not support current demands for a
moratorium on field trials. The whole purpose of these trials
is to investigate the safety of genetically modified crops and
their impact on the environment. Stopping the trials would merely
delay answering these vital questions.
13. We are aware of the current debate regarding
a proposed seven year monitoring period. Clearly consumer concerns
about the safety of the technology cannot be ignored. Any regulations
on monitoring should take account, as far as possible, of the
need to protect the competitiveness of the UK and European industries.
Also, the financial burden should not fall on industry alone.
14. We recognise that some concerns relate to
the cumulative effects of different applications of genetic modification
in agriculture and that there are calls for an overview to be
taken of the broader impact of the technology and its applications.
We believe that there is merit in following this line of enquiry,
that ACRE is the appropriate body to be given this remit and that
its terms of reference should be amended accordingly.
15. As a food manufacturer UB has considerable
interest in the regulation of labelling of GM foods. We believe
that the provision of information to consumers, including appropriate
product labelling, is an essential element in achieving consumer
acceptance of genetically modified foods.
16. The fact that comprehensive EU labelling
regulations were not agreed before genetically modified soya and
maize appeared on the market is a major reason why these productsand
indeed the whole principle of genetically modifying foodshave
attracted extremely negative media coverage and increasing consumer
hostility. The problems caused by the delays in agreeing these
regulations, and before them the novel food regulations, should
not be underestimated. Delays in implementation of regulations
continue, neither a deminimus threshold nor list of exempt ingredients
has been established and yet the regulation is to be law from
1 September 1998.
17. We welcome the fact that EU regulations
have finally been made on the labelling of GM soya and maize.
Whilst these effectively reinterpret the concept of "substantial
equivalence" set out in the novel food regulations, and thereby
once more apply a different standard for genetically modified
foods compared with other novel foods, we recognise that this
was a pragmatic solution given the prevailing political environment.
18. The vast majority of UB products including
all of McVitie's biscuits, McVitie's Prepared Foods and KP snack
products do not contain GM soya or maize material which we believe
would trigger labelling. However, as stated above (point 16) there
remains lack of clarity regarding what the trigger point is. Of
the small number of UB products which we believe will trigger
labelling under the above rules, most are already being labelled
under the voluntary industry guidelines which were agreed in January
1998 in the absence of progress at EU level. We will progressively
introduce labelling of the rest by the 1 September deadline.
19. Whilst the EU regulations are an important
step forwards it is imperative that the threshold levels for adventitious
contamination are agreed and analytical methods developed as a
priority so that the regulations can be properly enforced. It
should be recognised that as detection methods become increasingly
sensitive, threshold levels should not be reduced accordingly.
20. As already mentioned we believe that both
the well established UK system and now the EU regulations satisfactorily
ensure the safety of genetically modified organisms. However,
in some regards they put Europe at a disadvantage compared with
the US and others.
21. Ideally regulation of genetic modification
in agriculture should be harmonised at an international level
and a risk-based approach should be adopted. This should be achieved
through the Codex Alimentarius Commission although the time that
body takes to research decisions raises serious questions about
16 July 1998